Wednesday, June 17, 2015

The Agricultural Land Reform Code has been designed to promote economic and social stability. Being a social legislation, it must be interpreted liberally to give full force and effect to its clear intent, which is ‘to achieve a dignified existence for the small farmers’ and to make them ‘more independent, self-reliant and responsible citizens, and a source of genuine strength in our democratic society[7]’.

At any rate, respondent cannot legally invoke the strict application of the rules on prescription because the failure of petitioner to immediately file the Petition was due to its own maneuvers.[8] This Court should not allow respondent to profit from its threats and intimidation. Besides, if we subscribe to respondent’s ratiocination that petitioner’s cause of action had already prescribed, it would lead to an absurd situation wherein a tenant who was unlawfully deprived of his landholding would be barred from pursuing his rightful claim against the transgressor.[9]

We have ruled time and again that litigants should have the amplest opportunity for a proper and just disposition of their cause – free, as much as possible, from the constraints of procedural technicalities. In the interest of its equity jurisdiction, the Court may disregard procedural lapses so that a case may be resolved on its merits. Rules of procedure should promote, not defeat, substantial justice. Hence, the Court may opt to apply the Rules liberally to resolve substantial issues raised by the parties.

Rules of procedure ought not to be applied in a very rigid, technical sense, for they are adopted to help secure, not override, substantial justice, and thereby defeat their very ends. Indeed, rules of procedure are mere tools designed to expedite the resolution of cases and other matters pending in court. A strict and rigid application of the rules that would result in technicalities that tend to frustrate rather than promote justice must be avoided.[10]

“It is a better rule that courts, under the principle of equity, will not be guided or bound strictly by the statute of limitations or the doctrine of laches when to do so, manifest wrong or injustice would result.”[11] It must also be emphasized that “[t]he statute of limitations has been devised to operate primarily against those who slept on their rights and not against those desirous to act but cannot do so for causes beyond their control.”[12]

Petitioner’s tenure on the farm should be deemed uninterrupted since he could not set foot thereon. And if he could not make the required payments to Chioco or the Land Bank of the Philippines, petitioner should not be faulted. And, since his tenure is deemed uninterrupted, any benefit or advantage from the land should accrue to him as well.

Our law on agrarian reform is a legislated promise to emancipate poor farm families from the bondage of the soil. P.D. No. 27 was promulgated in the exact same spirit, with mechanisms which hope to forestall a reversion to the antiquated and inequitable feudal system of land ownership. It aims to ensure the continued possession, cultivation and enjoyment by the beneficiary of the land that he tills which would certainly not be possible where the former owner is allowed to reacquire the land at any time following the award – in contravention of the government’s objective to emancipate tenant-farmers from the bondage of the soil.[13]